DCT
1:21-cv-01712
Arlington Industries Inc v. Cooper Crouse Hinds LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Arlington Industries, Inc. (New York)
- Defendant: Cooper Crouse-Hinds, LLC (Delaware)
- Plaintiff’s Counsel: Morris, Nichols, Arsht & Tunnell LLP; Crowell & Moring LLP
- Case Identification: 1:21-cv-01712, D. Del., 12/03/2021
- Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is a Delaware limited liability company and is therefore deemed to reside in the district.
- Core Dispute: Plaintiff alleges that Defendant’s line of weatherproof electrical boxes infringes a patent related to a recessed outlet box design.
- Technical Context: The dispute concerns weatherproof electrical enclosures for outdoor use, a standard component in residential and commercial construction designed to protect electrical outlets from the elements.
- Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2004-06-09 | ’578 Patent Priority Date |
| 2006-01-01 | Plaintiff's first use of IN BOX® mark alleged to begin "at least as early as January 2006" |
| 2006-02-28 | ’578 Patent Issue Date |
| 2021-12-03 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,005,578 - "Rainproof Recessed Outlet Box"
- Patent Identification: U.S. Patent No. 7,005,578, "Rainproof Recessed Outlet Box," issued February 28, 2006 (’578 Patent).
The Invention Explained
- Problem Addressed: The patent’s background section describes prior art outdoor electrical enclosures as often being complex, multi-piece structures. It notes that when a standard outlet box is mounted flush with a wall surface, the outlet itself is vulnerable to damage from impacts that break the protective cover (’578 Patent, col. 1:16-48).
- The Patented Solution: The invention is a recessed electrical box, preferably made of two main pieces (a box member and a cover), designed to place the electrical outlet "substantially behind the wall surface" (’578 Patent, col. 1:50-53). This recessed positioning provides greater protection for the enclosed electrical device from external impacts. The design also incorporates flanges that act as a "positioning arrangement" to ensure the box is installed at the correct depth relative to the exterior surface, whether on a finished wall or during new construction (’578 Patent, Abstract; Fig. 2A).
- Technical Importance: The design aims to simplify construction and installation while increasing the durability and safety of outdoor electrical outlets by physically recessing them into the building structure (’578 Patent, col. 2:18-21, 33-35).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 1 (Compl. ¶33).
- Essential elements of independent claim 1 include:
- A first box with side walls, a back wall, and a front opening for receiving an electrical device.
- A transverse wall portion extending outwards from the first box's front edge, forming a partial back wall of a second box.
- A second box with side walls and a front opening.
- The side walls of the second box having a depth that positions the front edge of the first box "substantially behind said surface."
- A securement arrangement on the side walls of the first box for securing the electrical device.
- A cover arrangement for closing the front opening of the second box in a "rain tight closure."
- The complaint does not explicitly reserve the right to assert dependent claims but alleges infringement of "one or more claims" (Compl. ¶32).
III. The Accused Instrumentality
Product Identification
- Product Identification: Defendant’s "Extra duty recessed while-in-use covers" line of products, with model WIUR1W1 identified as an exemplary product (the "Accused Products") (Compl. ¶16, ¶31).
Functionality and Market Context
- The complaint alleges the Accused Products are weatherproof electrical boxes for outdoor installation (Compl. ¶16). It specifically alleges the products are marketed as "recessed while-in-use covers" suitable for installation on surfaces like siding and brick exteriors (Compl. ¶35).
- The complaint alleges that Defendant is a direct competitor to Plaintiff and that the Accused Products compete for sales in the same distribution channels (Compl. ¶18).
IV. Analysis of Infringement Allegations
’578 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first box having side walls, a back wall, a front opening... and a cavity for receiving an electrical device therein | The Accused Product comprises a "first box" with the claimed structural features. An annotated image in the complaint identifies this component. (Compl. ¶36). | ¶36 | col. 9:41-44 |
| a transverse wall portion extending outwards from said front edge and forming a partial back wall of a second box | The Accused Product has a transverse wall that extends from the front of the first box to form part of a second box. An annotated image in the complaint identifies the "second box" structure. (Compl. ¶37). | ¶37 | col. 9:45-47 |
| said second box including side walls and a front opening | The Accused Product's "second box" includes side walls and a front opening. | ¶37 | col. 9:48-49 |
| said side walls of said second box of a depth that said front edge of said first box is positioned substantially behind said surface | The side walls of the Accused Product's second box are deep enough to position the front edge of its first box "substantially behind said surface." | ¶38 | col. 9:49-51 |
| a securement arrangement on said side walls of said first box for securing said electrical device thereto | The Accused Product includes a securement arrangement inside the first box for mounting an electrical device. An annotated image highlights screw holes intended for this purpose. (Compl. ¶39). | ¶39 | col. 9:52-54 |
| a cover arrangement for closing said front opening of said second box in a rain tight closure | The Accused Product has a cover described as "weatherproof" that closes the front opening of the second box. An annotated image identifies this cover. (Compl. ¶40). | ¶40 | col. 9:55-57 |
- Identified Points of Contention:
- Scope Questions: A central dispute may arise over the meaning of "substantially behind said surface." The analysis may question how "substantially" is measured and what constitutes "said surface" in the context of various exterior wall materials (e.g., siding, brick, stucco).
- Technical Questions: The complaint's images depict a multi-part structure for the accused electrical box (Compl. ¶36-37). A question for the court may be whether this structure, which appears to be an assembly of components, meets the claim limitations of a "first box" connected to a "second box" via a "transverse wall portion," particularly as the patent's preferred embodiment describes these elements as being integrally molded in one piece (’578 Patent, col. 5:10-12).
V. Key Claim Terms for Construction
The Term: "substantially behind said surface"
Context and Importance: This term is critical as it defines the core inventive concept of a "recessed" box that offers enhanced protection. The degree of recess required by the term will likely be a key determinant of infringement.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "substantially" is not given a precise numerical value in the specification, which may support an argument that any configuration not flush with or protruding from the surface meets the limitation.
- Evidence for a Narrower Interpretation: The patent’s "Background of the Invention" emphasizes the goal of "providing additional protection to the outlet from hard impacts" (’578 Patent, col. 1:51-53). This purpose-driven language, combined with diagrams like Figure 2A showing a significant recess, may support a construction requiring a depth sufficient to achieve this protective function.
The Term: "transverse wall portion"
Context and Importance: This structural element links the "first box" and "second box." Its required shape and orientation could be a point of dispute. Practitioners may focus on this term because the physical geometry of the connection between the inner and outer sections of the box is fundamental to the claimed structure.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself does not specify a precise angle or shape for the wall, potentially covering a range of connecting structures.
- Evidence for a Narrower Interpretation: The detailed description states that the "transverse wall portion 34 extends outwardly and orthogonally from the peripheral sidewalls 26" (’578 Patent, col. 5:5-7). This language could be used to argue that the term requires a wall that is perpendicular to the sidewalls of the first box, potentially narrowing the claim's scope.
VI. Other Allegations
- Indirect Infringement: The complaint alleges direct infringement under 35 U.S.C. § 271(a) (Compl. ¶33, ¶43). It does not plead specific facts to support claims of induced or contributory infringement.
- Willful Infringement: The complaint alleges that the Defendant "has had knowledge of the '578 patent at least as early as of the date of this Complaint" (Compl. ¶42). This allegation appears to support a claim for post-filing willfulness but does not assert that Defendant had knowledge of the patent prior to the lawsuit's filing.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: how should the term "substantially behind said surface" be construed? The court's interpretation of this relative and qualitative term—whether it requires a specific minimum depth or is defined by the functional goal of enhanced impact protection—may be dispositive on the question of infringement.
- A second key question will be one of structural interpretation: does the accused product's physical construction embody the claimed architecture of a "first box" connected to a "second box" via a "transverse wall portion"? The dispute may focus on whether the separate components of the accused product function as the integrated structure described and claimed in the patent.